Control Number: 44547 Item Number - PUC Interchange
Transcription
Control Number: 44547 Item Number - PUC Interchange
Control Number : 44547 Item Number : 15 Addendum StartPage : 0 KATY PRAIRIE CONSERVANCY APRIL 24, 2015 PUC DOCKET NO. 44547 0 15 1"^^ ,« 2 4 P (1 [^ 2 3 APPLICATION OF CENTERPOINT ENERGY HOUSTON ELECTRIC, LLC TO AMEND A CERTIFICATE OF CONVENIENCE AND NECESSITY FOR A PROPOSED 345 KV TRANSMISSION LINE WITHIN GRIMES, HARRIS, AND WALLER COUNTIES, TEXAS § § § § § § § § .,.^ -t BEFORE THE ^li,I iS, CLErit; PUBLIC UTILITY COMMISSION OF TEXAS KATY PRAIRIE CONSERVANCY'S MOTION TO INTERVENE TO THE HONORABLE ADMINISTRATIVE LAW JUDGE: COMES NOW, Katy Prairie Conservancy ("KPC" or Movant) and, under P.U.C. PROC. R. §§22.103 and 22.104, timely files this Motion to Intervene in the above-referenced proceeding and in support thereof respectfully shows as follows: 1. IDENTITY OF INTERVENOR Katy Prairie Conservancy 3015 Richmond Avenue, Suite 230 Houston Texas 77098-3114 II. LEGAL REPRESENTATIVE The name, mailing address, telephone number, and email address of the Movant's legal representative is: Bradford W. Bayliff Bayliff Law Firm PLLC Capital Office Hill Country Office 111 Congress Avenue, Suite 400 420 Crosswind Drive Austin, Texas 78701 Blanco, Texas 78606 (512) 480-9900 Telephone (512) 480-9200 Facsimile bbayliff@RegLawFirm.com Movant requests that all pleadings, orders, correspondence, and filings be served on its legal representative at his Hill Country office. z III. BASIS FOR INTERVENTION Katy Prairie Conservancy owns and holds conservation easements for property that may be adversely affected, as that term is defined in P.U.C. Proc. R. §22.52(a)(3), by the proposed transmission line that is the subject of the application in this docket. Specifically, KPC owns and holds conservation easements for property that would be affected if the project is constructed on several links or segments included in CenterPoint's application. KPC is included on the Landowner Mailing List included as part of the application filed by CenterPoint Energy Houston Electric, LLC. Katy Prairie Conservancy, therefore, has justiciable interests that may be adversely affected by the outcome of this docket and on that basis it seeks to intervene. KPC's interests are physically and legally distinct from any other party and no other party can adequately represent its interests. Katy Prairie Conservancy requests this Motion to Intervene be granted and that KPC be recognized as a party to this proceeding. IV. ACKNOWLEDGEMENTS Katy Prairie Conservancy acknowledges that: (1) it will be a party to the case; (2) it will be required to respond to all discovery requests from other parties in the case; (3) if KPC files testimony, other parties may cross-examine at a hearing any KPC witness(es) providing testimony in this case; (4) if KPC files any documents in this case, copies of those documents must be provided to every other party to this case under the rules of the Public Utility Commission of Texas and orders of the Administrative Law judge; and (5) KPC is bound by the Procedural Rules of the Public Utility Commission of Texas and the State Office of Administrative Hearings. V. CONCLUSION AND PRAYER WHEREFORE, PREMISES CONSIDERED, Katy Prairie Conservancy respectfully requests this Motion to Intervene be granted, that it be allowed to participate as a party to this proceeding, and for such further relief to which it may be entitled. 2 Respectfully submitted, BAYLIFF LAW FIRM PLLC 420 Crosswind Drive Blanco, Texas 78606 (512) 480-9900 (512) 480-9200 (facsimile) By: BradforxW. Bayliff State Bar No. 24012260 bbayliff@reglawfirm.com ATTORNEY FOR KATY PRAIRIE CONSERVANCY CERTIFICATE OF SERVICE I certify that on April 24, 2015, a copy of the foregoing document is being served via email, facsimile, U.S. mail, and/or hand delivery to all parties of record. Bradford W. Bayliff